Cumulative PG Residency Across Institutions Valid If Prospectus Is Silent: Delhi High Court Quashes AIIMS' Rejection Of Top Rank Holder

The Delhi High Court has quashed a decision of the All India Institute of Medical Sciences (AIIMS) cancelling the candidature of a top-rank holder for admission to the DM (Critical Care Medicine) course, holding that postgraduate residency of 1,095 days can be cumulative across institutions when the prospectus does not mandate training from a single institute.Justice Jasmeet Singh held that AIIMS could not introduce an additional eligibility condition at the final stage of admission when the prospectus governing the selection process was silent on such a requirement. The bench observed,“A plain and conjoint reading of both, the Clause 4.3.2 and the regulation 2.1, to my mind, shows that it requires “requisite qualification, degree and tenure” being 3 years by the prescribed date. The aforesaid Clause is totally silent on the fact that the 3 year requirement has to be from a single institute or the same can be considered when fragmented in durations.”Petitioner had secured a high rank in the Institute of National Importance Super-Specialty entrance exam and was provisionally selected. However, AIIMS subsequently cancelled his candidature on the ground that his three-year postgraduate residency was completed across more than one institution.Petitioner argued that the prospectus only required completion of 1,095 days of PG training and did not stipulate that the residency must be undertaken in a single institution.AIIMS on the other hand defended its action by asserting that continuity of residency at one institution was implicit in the eligibility criteria and necessary to maintain academic standards.Rejecting this contention, the High Court observed,“The respondent's argument that such a requirement is implicit and in the interest of ensuring professional competence is bereft of reasoning. Any eligibility condition must be clear, explicit and uniformly applicable.”It added, “The Clause 4.3.2 of prospectus issued by the respondent no. 1 Institution, only requires 1095 days of residency requirement and not that the same has to be continuous and from one recognised institution only. Once the language of prospectus is clear and unequivocal, it cannot be left to the discretion of the respondent No. 1 Institution to add words and interpret in a way which is not borne out from the plain reading.”The Court further observed that while judicial restraint is generally exercised in academic matters, such deference does not extend to situations where an academic authority acts arbitrarily or in a manner inconsistent with the governing prospectus. Accordingly, the Court set aside AIIMS' decision rejecting the petitioner's candidature and directed that his admission be processed in accordance with law.Appearance: Ms. Anushree Kapadia, Mr. Pranay Bhardwaj, Mr. Shivank Singh, Advs. for Petitioner; Mr. Anand Varma, Mr. Ayush Gupta, Advocates. Mr. Kanav Vir Singh (SPC) for R-2 Mr. Siddharth Garg (Adv), Mr. Himanshu Chaubey (Adv), Mr. Srijan Sinha (Adv), Ms. Lihzu Shiney Konyak (Adv), Mr. Srajan Yadav (Adv), Ms. Trisha Garimala (Adv) for R-3 Mr. Kapil Midha, Ms. Muskaan Garg, Advs. for R-5; Mr. T Singhdev, Mr. Abhijit Chakravarty, Mr. Tanishq Srivastava, Mrs. Yamini Singh, Mr. Vedant Sood, Advs. for NMCCase title: Meet Bhadresh Shah v. All India Institute Of Medical Sciences & Ors.Citation: 2026 LiveLaw (Del) 135Case no.: W.P.(C) NO. 78/2026Click here to read order

Cumulative PG Residency Across Institutions Valid If Prospectus Is Silent: Delhi High Court Quashes AIIMS' Rejection Of Top Rank Holder

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